The panel explained the pros, cons and procedural steps for disclosing under the Office of Inspector General’s Self-Disclosure Protocol using the recent update as a springboard for the discussion and under the CMS Self-Referral Disclosure Protocol. They also discussed effective approaches for evaluating whether to self-report violations and for achieving favorable outcomes.

Specifically the panel reviewed these key questions:

What are some key aspects of the April 2013 updated Provider Self-Disclosure Protocol?

What factors should healthcare providers consider when determining whether and when a potential Stark Law violation should be disclosed?

What are the best practices for healthcare providers and their counsel when preparing the SDP disclosure submission?